At the time Martin v. City of Boise was decided, over half a million individuals in America were unhoused on any given night. Of this number, two-thirds were sheltered and one-third were unsheltered. Municipalities have often responded to the problem of homelessness by prosecuting unsheltered individuals under vagrancy laws or by enacting no sit/sleep/lie statutes. The City of Boise follows this tradition of criminalizing the unsheltered, or unhoused. Boise’s Camping Ordinance makes it a misdemeanor for individuals to camp in public, and its Disorderly Conduct Ordinance prohibits individuals from occupying a public or private space without permission from the owner.